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                             February 23, 2024

       Sandeep S. Aujla
       Executive Vice President and Chief Financial Officer
       Intuit Inc.
       2700 Coast Avenue
       Mountain View, CA 94043

                                                        Re: Intuit Inc.
                                                            Form 10-K for the
fiscal year ended July 31, 2023
                                                            File No. 000-21180

       Dear Sandeep S. Aujla:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the fiscal year ended July 31, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 37

   1.                                                   We note that in your
earnings call for the quarter ended October 31, 2023, your CEO
                                                        indicated that the
company looks at metrics around number of customers, conversion,
                                                        retention and average
revenue per customer (ARPC) across the entire franchise, as well as
                                                        by area and that the
metric that will matter the most for Full Service is going to be
                                                        ARPC. We also note that
in your earnings release for the quarter ended July 31, 2023
                                                        you disclosed TurboTax
Federal Unit Data. Please tell us whether these metrics are key
                                                        performance indicators
used in managing your business and if so, please include a
                                                        quantified discussion
of these metrics for each period presented in your periodic filings.
                                                        Refer to SEC Release
No. 33-10751.
 Sandeep S. Aujla
FirstName
Intuit Inc. LastNameSandeep S. Aujla
Comapany23,
February    NameIntuit
              2024     Inc.
February
Page  2 23, 2024 Page 2
FirstName LastName
Segment Results, page 39

2.       We note your discussion of segment results, starting on page 37,
describes multiple factors
         that impacted results in each reporting period, however, you provide
no quantification of
         the impact of each factor. For example:

                You disclose that Online Ecosystem revenue increased due to an
increase in
              customers, higher effective prices and a shift in mix to
higher-priced offerings as well
              as higher Mailchimp revenue.
                The operating income discussion for the Small Business &
Self-Employed segment
              describes the year-over-year increase as primarily due to
increase in revenue and
              partially offset by higher staffing expenses, sales-related
expenses, and outside
              services expenses.
                Revenue for the Consumer segment discussion describes the
increase as primarily
              due to a shift in mix to your higher-priced product offerings as
well as higher
              effective prices, partially offset by a decrease in total tax
returns.

         Where a material change is attributed to two or more factors,
including any offsetting
         factors, please revise throughout your results of operations
discussion to ensure you
         include a quantified discussion of each factor and avoid using terms
such as "primarily" or
         "substantially all" in favor of specific quantification. Similar
concerns apply to your
         Forms 10-Q. Refer to Item 303(b) of Regulation S-K.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 with any
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Technology
cc:      Kerry McLean